GENIEX Terms of Use


Last updated: April, 2022

Preamble
Welcome to GENIEX!

GENIEX-TECH NIGERIA LIMITED (hereinafter referred to as “GENIEX”, "we”, “us”, “our”) is the service provider and operator of GENIEX and its Service (hereinafter referred to as “This Application”). We fully respect your privacy and will do our utmost to protect the security of your personal information. We may collect, use or otherwise process your personal information based on your consent or in accordance with the relevant provisions of applicable laws and regulations during your use of this Application or its services (collectively, our “Service”). This Privacy Policy (hereinafter referred to as “Policy”) is meant to help you understand how we collect, use, disclose, process and protect your personal information with regard to your use of GENIEX and its Service, your rights regarding the personal information provided to us, and how we safeguard your rights. This Policy applies to all the products and services provided by GENIEX, including applications, mini-programs, websites, SDK for third-party websites or applications, APIs and other forms that may be available in the future.

You agree that by clicking the “Agree” button on the webpage/pop-up window or accessing or using GENIEX and its services, you are deemed to have read, understood and agreed to be bound by this Agreement (Including: Palmpay Terms of Service). If you do not agree with this agreement, please do not use GENIEX or its service.

If you have any questions or comments regarding this Agreement, please contact us via ["User Feedback" in "My" of GENIEX]. We will be happy to answer your questions.



1. General Terms

1.1 The Service under this Agreement: refers to the oriented traffic package ordering services that we provide you via GENIEX.

1.2 Scope of this Agreement. This Agreement applies to all the products and services provided by GENIEX, including applications, mini-programs, websites, SDK for third-party websites or applications, APIs and other forms that may have in the future, and please refer to the specific services provided by GENIEX.

1.3 Protection of minors. If you are under the age of 18 (or under the age of majority in the jurisdiction where you use GENIEX and Service), you represent that you have reviewed this Agreement with your parent or legal guardian and that you and your parent or guardian understand and consent to this Agreement. If you are a parent or guardian permitting a Minor to use GENIEX and the Services, you agree to: (i) supervise the Minor’s use of GENIEX and Service; (ii) assume all risks associated with the Minor’s use of GENIEX and Service, including the transmission of content to and from third parties via the Internet; (iii) assume any liability resulting from the Minor’s use of GENIEX and Service; (iv) ensure the accuracy and truthfulness of all information submitted by the Minor; and (v) assume responsibility and are bound by this Agreement for the Minor’s access and use of GENIEX and Service.

1.4 Updates of this Agreement. In order to improve your user experience or enhance product safety performance, we will continue to work hard to develop new software and services, and provide you in a timely manner with software updates (including but not limited to software version upgrades, modifications, and functional perfection) or repairs. We reserve the right to modify this Agreement as necessary in accordance with applicable laws and regulations. The updated Agreement will shall supersede the original Agreement and shall come into effect after the expiration of the period stipulated by applicable law. If there is no special provision in applicable laws, the Agreement shall become effective on the date of renewal. The updated Agreement will be announced on GENIEX for your reference at any time. Your continued access or use of GENIEX or Service will be deemed as you have read and agreed to be bound by the updated Agreement. If you do not accept the updated Agreement, please stop using GENIEX or Service.


2. Permitted License Uses

Subject to the terms and conditions of this Agreement, GENIEX grants you a non-exclusive, non-sublicensable, personal, revocable, limited license to access and use this Software and Service. You may install, use, display, and run the Software and Service on your legally owned device for non-commercial purposes. We reserve all rights not expressly authorized to you regarding GENIEX in this Agreement. If you wish to obtain other rights with regard to the use of GENIEX, you shall separately obtain a formal written permission from us.


3. GENIEX and its Services

3.1 GENIEX is a software independently developed by us. The services it provides include but is not limited to:

(1) Oriented traffic packages: we will provide you with application oriented traffic packages. You won’t have to consume the network traffic provided by the operator or pay any additional network traffic fees after you buy the oriented traffic package and use the applications, and you should buy the traffic package again when it is used up or expired;

(2) General traffic packages: we will provide you with general traffic packages. You won’t have to consume the network traffic provided by the operator or pay any additional network traffic fees after you buy the general traffic package and use the applications, and you should buy the traffic package again when it is used up or expired;

(3) Traffic package management: you may check your order and order use through this Service to monitor your traffic use;

Please understand and acknowledge that our services may be adjusted and updated from time to time according to your demands or our operational needs. Please refer to the real-time display of our service and features in the webpage of GENIEX or other service interfaces (if any).


3.2 You understand and agree that we may send you relevant information, advertisements or brand promotion services for you during your use of this Software and related Services, we will also display commercial advertisements, promotions or information (commercial or non-commercial) regarding this Software and Service and/or third-party providers or business partners. If you do not wish to receive personalized advertisement notifications, you can turn off such personalized advertisement notification, but you may still receive non-personalized advertisements in our App. If you receive advertisements via emails or text messages, you have the right to unsubscribe them.


3.3 You understand and agree that the Software and Service may be suspend ed or stopped by us based on our own business development or as required by judicial, regulatory and supervisory authorities.


3.4 Unless permitted by applicable law and with our written authorization, you may not use or otherwise export or re-export this Software and Service.



4. Restrictions on the use of This Software and Service

4.1 You shall not take any of the following actions when using this Software and Service, including but not limited to:


4.1.1 Releasing, transmitting, spreading or storing contents which violate laws and regulations, policies, public order and good custom, and social ethics, such as insults, defamation, violence, or violation of religion, etc; releasing, transmitting, spreading or storing fabricated information or advertising information for the purpose of misleading or deceiving others;


4.1.2 Renting, lending, copying, modifying, linking, reprinting, compiling, issuing or publishing this Software and similar acts;


4.1.3 Jailbreaking, reverse engineering, disassembling, decompiling, or otherwise attempting to destroy this Software; or, accessing or disturbing this Software by the use of plug-ins, add-ons, or third-party tools/services that are not authorized by us;


4.1.4 Copying, modifying, adding, deleting, operating in the form of mounting, or creating any derivative works of data of the Software, data released into any terminal memory in the course of the operation of the Software, interactive data of the client and server side in the course of the operation of the Software, and system data necessary for the operation of the Software; or adding, deleting or changing the functions or operative effect of software by modifying or fabricating the instructions and data that occur in the course of the operation of the software; or operating or publicly diffusing the software and method used for the above purposes, whether commercially or otherwise;


4.1.5 Carrying out other acts which violate laws and regulations, policies, public order and good custom, and social ethics or acts which are not authorized by us in writing.


4.2 You may not, and you agree not to or enable others to, copy (except as expressly permitted by this Agreement), decompile, reverse engineer, disassemble, attempt to derive the source code of, decrypt, modify, or create derivative works of GENIEX or any services provided by GENIEX or any part thereof (except as and only to the extent any foregoing restriction is prohibited by applicable law or by licensing terms governing the use of open-source components that may be included with GENIEX). You agree not to remove, obscure, or alter any proprietary notices (including trademark and copyright notices) that may be affixed to or contained within GENIEX.



5. Intellectual Property; Ownership

We reserve the intellectual property rights to this Software and Service and all related information content (including but not limited to UI interface design, pictures, fonts, audio, etc.) and all rights not expressly granted to you. The above intellectual property rights, including but not limited to copyright, trademark and patent rights, are protected by applicable intellectual property rights, anti-unfair competition and other respective laws, regulations and relevant international treaties. For matters not expressly authorized in this Agreement, such as commercial sales, reproduction, and permission for any third party to use this Software, you should separately obtain formal written permission from us.



6. Considerations on Your Use of This Software and Service

6.1 You fully understand and agree: when you use a specific service of this Software, relevant permissions and interfaces of your device may be required in order to achieve the corresponding features, while a separate user agreement may also be required for certain services. Please read the afore-mentioned relevant agreements and rules carefully before using this service;


6.2 We have the right to display all kinds of information to you in the process of providing this Service, including but not limited to prompts for authorization, advertising information and promotional information, etc. The information may appear in the form of system messages or pop-up windows. If you do not agree to receive certain information, you can cancel the relevant service, which may eventually lead to unavailability of the relevant service function;


6.3 You understand and agree: We will make commercially reasonable efforts to protect your data storage security during your use of this Service, but we cannot provide a complete guarantee, including but not limited to the following situations:


6.3.1 To the maximum extent permitted by law, we are not responsible for your deletion or storage failure of relevant data in this Software and Service;


6.3.2 We will retain the data according to the minimum retention period required for business development, unless you agree to extend the retention period or otherwise permitted by law. We also have the right to decide at our discretion the maximum storage space of data in GENIEX. You may back up relevant data in this Software and Service by yourself according to your own needs;


6.4 When you use this Service, the specific content displayed may differ depending on the version of the Software you use. You understand and agree: when you are using a certain version of this Software or entering the relevant pages of an application developed by us, in order to provide you with a better service experience, the necessary information such as the installation location, size, and UI interface of the installed application on your terminal device may be adjusted, depending on the actual version provided by us.


6.5 You fully understand and agree that, if you need to register an account when using this Software, you will be responsible for keeping the security of the registered account information and account password properly, and you will be responsible for all acts that occur under the account you registered, including any contents that you publish and any consequences arising therefrom.


6.6 You shall judge by yourself the contents that you access while using this Service and bear the risks arising from the use of such contents, including risks arising from the dependence upon the correctness, completeness or practicability of the contents. We are unable to and will not bear any responsibility for any loss or damage suffered by you due to the above risks.


6.7 If we find or receives a report from others that you violated the terms of this Agreement, we shall have the right at any time without notice to: delete and shield relevant contents; suspend or terminate your use of the corresponding account or all of the Service; investigate legal responsibility and take other measures. If you violate any terms of this Agreement, thus causing damage to any third party, you shall solely bear all responsibilities arising therefrom and compensate us for any losses suffered by us arising therefrom (including but not limited to possible administrative penalties, lawyer fees, and investigation and evidence collection fees).



7. Updates

In order to better provide you with relevant Service and to guarantee the security of this Software, we may update this Software and relevant Services from time to time (including but not limited to software modification, software upgrades, partial function disabling, function strengthen, new service development, software replacement and function improvement). You may choose whether to upgrade to the corresponding version based on your needs. In order to facilitate your experience of a better service of GENIEX, and in compliance with applicable laws, this Software may enable automatic upgrade and update function for you by default. You can choose whether to enable this function in software settings. In case of such updates, we will notify you in an appropriate manner (including but not limited to system notifications, site messages, announcements, application store update notifications, etc.), and you have the right to choose whether to accept the updated version. Updating to the latest version may improve your user experience. If you decide not to accept the updated version provided by GENIEX, you understand that you may place the Software under serious security risk or cause the Software to be unusable or unstable. Failure to update the software may cause some of the functions of the Software to be limited or rendered unusable.



8. Software and Services Provided by Third Parties

8.1 In order to facilitate your use of GENIEX, this Software or this Service may use third-party software or services, and the results of such use and access are provided by the third party (including but not limited to the services and contents provided by the third party that you jump to through this Software, this Service, or accessed by said third party through GENIEX's open platform). In addition to the terms of this Agreement, you shall comply with the user agreements of third parties in using software or services provided by third parties. We cannot guarantee the security, accuracy and validity of the services and contents provided by third parties and other uncertain risks, and to the fullest extent permitted by applicable law, you shall solely bear relevant risks and responsibilities arising therefrom.


8.2 Whether the third-party software or services are pre-installed in GENIEX or activated or subscribed by yourself, you understand and agree that we disclaims all express or implied warranties with respect to the security, accuracy and validity of the services and contents provided by third parties and other uncertain risks.


8.3 Any dispute between you and the above third-party software and services providers shall be settled by you and such third party with you taking relevant responsibilities, if any.



9. Fees and Advertisement

You understand and agree that although this Software and Service are currently offered to you free of charge, however, along with the continuous renewal of our Service, you may need to pay for some part of the Software or Service provided by GENIEX. We reserve the right to add fee-charging features and functionalities in future Service. We also reserve the right to display advertisements in connection with the Software and Service to you. We will clearly notify you in case of any paid software and service in this Software before your use and you may choose whether to accept or use such paid software or service. At that time, please use such paid software or service according to our instructions (including but not limited to service fee standards, payment terms and service rules). You can use such paid software and services once you have explicitly agreed to the relevant agreement and are willing to pay the fees.


Your use of this Software and Service will consume your device, bandwidth, traffic and other resources. Fees for the above resources such as Internet access fees, SMS fees, and payment for the Software's value-added services shall be borne by yourself.



10. Privacy Policy

When you are using GENIEX and Services, we may need to collect personal data to provide you the Services. we pay great attention to the protection of your personal data and has made GENIEX Privacy Policy, which states the detailed information of the way GENIEX collects, uses, stores, transfers, and discloses your personal data. You may refer to the details of the "Privacy Policy" at “My” > “About Us” > “Privacy Policy”, which forms an integral part of this Agreement. By downloading, installing or using the Services, you agree to be bound by the terms of this Agreement and its Privacy Policy, and we will protect your privacy in accordance with this Privacy Policy.



11. Termination and Breach of Contract

We have the right to judge whether your behavior complies with the terms of this Agreement. If you are deemed to have violated relevant laws and regulations or fail to comply with any terms and conditions of this Agreement or related rules, based on the severity of your violation, GENIEX and our licensors shall have the right to delete the content in violation, to limit, to suspend or to terminate your use of this Software and Service without notice, and to take other measures that we consider appropriate. And you will be held liable for your incompliance behavior. Once it is terminated, we will continue to retain the information you stored in GENIEX according to requirements of applicable laws and regulations and delete the information generated during your use of this Software in our database in a reasonable period. You agree that, to the fullest extent permitted by applicable law, we shall not be liable to you for such deletion.



12. Indemnification

You will indemnify, release and hold harmless us, our licensors, agents, and all senior managements, directors, employees thereof from and against any and all third party claims, actions, liabilities, losses, damages, judgments, costs and expenses, including reasonable attorneys’ fees (collectively, "Claims") arising out of (i) any use of the Services or products appearing on the Services by you or by any person that is not in accordance with the terms of this Agreement; (ii) any breach of this Agreement by you or by any person that you allow to use the Services; or (iii) any violation of any laws, regulations or the rights of any third party by you or by any person that you allow to use the Services or products appearing on the Services.



13. DISCLAIMERS

13.1 DISCLAIMER OF WARRANTIES. TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE SOFTWARE AND SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT ANY WARRANTIES OR GUARANTEES OF ANY KIND OR NATURE, EITHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING, BUT NOT LIMITED TO, ANY (IF ANY) IMPLIED WARRANTIES, DUTIES OR CONDITIONS OF MERCHANTABILITY, OF FITNESS FOR A PARTICULAR PURPOSE, OF ACCURACY OR COMPLETENESS OF RESPONSES, OF RESULTS, OF WORKMANLIKE EFFORT, OF LACK OF VIRUSES, AND OF LACK OF NEGLIGENCE, ALL WITH REGARD TO THIS SOFTWARE AND SERVICE.

13.2 THIS SOFTWARE DOES NOT CONTAIN ANY MALICIOUS CODE DESIGNED TO DESTROY YOUR DEVICE DATA OR TO OBTAIN YOUR PRIVACY INFORMATION. WE WILL ALSO DO OUR UTMOST TO ENSURE THE SAFE, PROMPT, EFFECTIVE, ACCURATE, RELIABLE AND CONTINUOUS OPERATION OF THIS SOFTWARE AND SERVICE, BUT WITH THE LIMITATION OF THE EXISTING TECHNOLOGY, THIS SOFTWARE AND RELATED SERVICE MAY BE AFFECTED BY VARIOUS UNSTABLE FACTORS, WE MAKE NO WARRANTIES OR REPRESENTATIONS THAT THE SOFTWARE IS COMPATIBLE WITH ALL SOFTWARE AND HARDWARE SYSTEMS, OR IS ERROR-FREE, CAN OPERATE WITHOUT INTERRUPTION OR THAT ANY ERRORS IN THE SOFTWARE OR RELATED SERVICE CAN BE CORRECTED. IN CASE OF CIRCUMSTANCES SUCH AS INCOMPATIBILITY OR SOFTWARE MALFUNCTION, PLEASE CONTACT US FOR TECHNICAL SUPPORT. IF THE COMPATIBILITY PROBLEM CANNOT BE SOLVED, YOU CAN DELETE THIS SOFTWARE. WITHIN THE MAXIMUM SCOPE PERMITTED BY APPLICABLE LAWS, WE ARE EXEMPT FROM ANY OF YOUR LOSSES CAUSED HEREIN.



14. LIMITATION OF LIABILITIES

TO THE EXTENT NOT PROHIBITED BY APPLICABLE LAW, IN NO EVENT SHALL US, OUR AFFILIATES, SENIOR MANAGEMENT, DIRECTORS, EMPLOYEES OR AGENTS BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA, BUSINESS INTERRUPTION OR ANY OTHER INTANGIBLE DAMAGES OR LOSSES, ARISING OUT OF THE FOLLOWING REASONS, HOWEVER CAUSED, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT OR OTHERWISE) AND EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES: (1) YOUR USE OR INABILITY TO USE THE SERVICE;(2) THE UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA; (3) THE DELETION OF, CORRUPTION OF, OR FAILURE TO USE YOUR TRANSMISSIONS OR DATA ON OR THROUGH THE SERVICE; (4) STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON THE SERVICE; AND (5) ANY OTHER MATTER RELATING TO THE SERVICE. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR PERSONAL INJURY, OR OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THIS LIMITATION MAY NOT APPLY TO YOU.


AT THE SAME TIME, OUR MAXIMUM COMPENSATION FOR ALL YOUR LOSSES SHALL NOT EXCEED THE AMOUNT YOU PAID FOR USING/PURCHASING THE CORRESPONDING SOFTWARE OR SERVICES (IF PAID SERVICE IS INVOLVED) WITHIN 12 MONTHS BEFORE THE DATE OF INITIATING THE CLAIM. IF THE LAW OF YOUR REGION DOES NOT ALLOW THE LIMITATION OF LIABILITY THROUGH AN AGREEMENT. IN THIS CASE, THE APPLICABLE LAWS AND REGULATIONS SHALL APPLY.



15. Governing Laws and Dispute Resolution

15.1 Governing Laws. The execution, performance, interpretation, modification and disputes settlement of this Agreement shall be governed by the laws of Hong Kong Special Administrative Region of the People's Republic of China, excluding its conflict-of-law provisions. You agree that this Agreement is signed in Hong Kong.


15.2 Arbitration. Any dispute or controversy between you and us based on this Agreement shall be first settled through friendly negotiation. If no settlement can be reached through friendly negotiation, you unconditionally consent and agree that any claim, dispute or controversy (whether in contract, tort or otherwise) you may have against any of our entities, the directors, agents, and employees of any of our entities shall be submitted to Hong Kong International Arbitration Center (HKIAC) for settlement before one (1) arbitrator in accordance with the rules of HKIAC. The arbitration shall take place in Hong Kong, China, and the arbitration proceedings and all pleadings and written evidence shall be in the English language, and judgment upon the award rendered by the arbitrators may be entered in any court having jurisdiction thereof. You will only be permitted to pursue claims against us on an individual basis, not as a plaintiff or class member in any class or representative action or proceeding.



16. Miscellaneous

16.1 Heading. The headings of all terms of this Agreement are for reference purpose only, have no actual meanings themselves, and shall not be used as a basis for interpreting the meanings of this Agreement.


16.2 Severability. If any term or provision of this Agreement is held to be invalid or unenforceable by any judicial or administrative authority for any reasons, such determination shall not affect the validity of enforceability of the remaining terms and provisions of the Agreement hereof, and the remaining provisions of this Agreement shall remain in full effect and shall be construed in accordance with its terms.


16.3 Languages. If this Agreement is made in English, Arabic and other languages. In case of any discrepancy, the English version hereof shall prevail.


16.4 No Waiver. Our failure to enforce at any time any of the provisions of GENIEX Services, or our failure to require at any time performance by you of any of the provisions of GENIEX Services, shall in no way be construed to be a present or future waiver of such provisions, nor in any way affect our right to enforce such provision thereafter. Our express waiver of any provision, condition or requirement of the GENIEX Services shall not constitute a waiver of any future obligation to comply with such provision, condition or requirement.


16.5 Entire Agreement. This Agreement constitutes the entire agreement between you and us governing your use of the Software and supersedes any prior agreements between you and us relating to the use of GENIEX. You may also be subject to additional terms and conditions that may apply when you use or purchase open-source software, third-party content, or other services.


GENIEX Privacy Policy

Last Updated: April 20, 2021

Effective date: April 20, 2021

The version No. of this Agreement: 20220420V1


GENIEX-TECH NIGERIA LIMITED (hereinafter referred to as “GENIEX”, "we”, “us”, “our”) is the service provider and operator of GENIEX and its Service (hereinafter referred to as “This Application”). We fully respect your privacy and will do our utmost to protect the security of your personal information. We may collect, use or otherwise process your personal information based on your consent or in accordance with the relevant provisions of applicable laws and regulations during your use of this Application or its services (collectively, our “Service”). This Privacy Policy (hereinafter referred to as “Policy”) is meant to help you understand how we collect, use, disclose, process and protect your personal information with regard to your use of GENIEX and its Service, your rights regarding the personal information provided to us, and how we safeguard your rights. This Policy applies to all the products and services provided by GENIEX, including applications, mini-programs, websites, SDK for third-party websites or applications, APIs and other forms that may be available in the future.


It is important to note that this Policy does not apply to services provided to you by other third parties. You may receive links, content, products or services provided by third parties (Including: Palmpay Privacy Policy), please prudently determine whether to access them. We encourage you to carefully review the privacy policies of any Third Parties you access before submitting any personal information.


We have chosen to use plain language in order to make sure that you fully understand this Policy and make your own choices. We have also marked or highlighted key terms in bold or capital letters for your attention. We will also notify you by a pop-up window when you first use our service to help you understand the core terms of this Policy.


Before using our products or services, providing your personal information to us or allowing us to collect your personal information, please read this Policy carefully to understand our practices regarding your personal information and access it frequently to understand the updates to this Policy. If we update this Policy, we will notify you by announcements in the product or website to let you know about the changes we made. By accessing or using our Services after we have placed such a notice, you are deemed to have accepted the updated Privacy Policy. You can check the “Effective Date” posted at the top of the Privacy Policy for the latest update time.


If you have any questions, please feel free to contact us by the following means:

[user-services@geniex.com]

You can also access this Privacy Policy by the following means:

GENIEX APP > ME > Setting > About Us > Privacy Policy

This Privacy Policy will help you understand the following contents:

I. How We Collect and Use Your Personal Information

II. How We Store and Protect Your Personal Information

III. How We Share, Transfer and Disclose Your Personal Information and Data

IV. How Your Personal Information is Transferred Across Borders

V. Your Rights to Your Personal Information

VI. How We Handle the Personal Information of Children

VII. Third-Party Service Providers and Services

VIII. Supplement and Update of the Policy

IX. Joint Controller

X. How to Contact Us



I. How We Collect and Use Your Personal Information

1. Overviews

GENIEX firmly believes that the fundamental privacy rights should not differ depending on where you live in the world. Any information relating to an identified or identifiable individual, in particular by reference to the individual's name, identification number, location data, and online identifier or to one or more factors specific to the physical, physiological, genetic, mental of that natural person will be treated as “Personal Information” by GENIEX, regardless of where such natural person lives.

We only collect the information that is necessary for specified, concrete, explicit and legitimate purposes and will ensure that the information is not further processed in a manner that is incompatible with those purposes. If we intent to use your personal information for other purposes not specified in this Policy, we will obtain your consent at that time.

We may collect your personal information by the following means:
1) information you provide directly to us (such as your nickname, profile picture, name and phone number you provide to us when you login to your account or take part in the promotion activity we held);
2) information we obtain automatically during your use of this Application (such as device information, service log information);
3) information we obtain from other sources.


You have the right to choose whether or not to provide the personal information when you use GENIEX and its Service or when we have requested. You are not required to provide your personal information to GENIEX, but in some cases, if you choose not to do so, GENIEX will not be able to provide you with related products or services, nor will we be able to respond or resolve the problems you've encountered. We will collect and use your personal information only for the purposes described in this Policy. The following describes your personal information that we collect:


2. What information we collect and how we use it in GENIEX

GENIEX mainly provides you with comprehensive services including oriented traffic package ordering service and traffic balance monitoring.


2.1 To provide you with the service of account registration and login services

To fully use the functions and services of the software conveniently, you can login by providing us with your mobile phone, in such case, we will collect your mobile phone number, mobile phone verification code and password. We will assign you an account ID when you finish the registration successfully. If you refuse to provide this information, you will not be able to register a GENIEX account or use relevant functions. However, your normal use of other features of GENIEX will not be affected. You can still browse and use the basic features of the software in tourist mode (i.e. without being a registered user).

When using this Application, you may choose to provide, fill in and modify your nickname (including your real name), profile picture (including your real portrait). However, your refusal to provide additional information will not affect your use of basic business functions.

This Service will rely on the SIMS service provided by the operator. For the purpose of prevention of cyber crime based on the Service, when you use this Service to access networking services, we will encourage you to submit your name and NIN number according to regulatory requirements. You acknowledge and confirm that we will try our best to ensure the security of your personal information, which will be obtained and used only for the purpose of real name authentication, but will not be disclosed or used for any other purpose.



2.2 To provide you with oriented traffic package ordering service

GENIEX provides you with oriented traffic package ordering services. For your normal use of our products and services, we will collect your language, mobile phone model, brand, application package name, OS version and IMEI number. Such information will help us provide appropriate traffic packages and customized applications for your choice according to your mobile device.

When you order traffic packages, to help you complete the payment, we will collect information such as your order number, payment channel, package information, purchase time and amount. You can view the above information through the order list at any time and manage your order. When the third-party payment channel requires you to fill in your email information, we will help the collection of your email address. When you use the third-party payment service, you will be bound by their privacy policy. Please read the privacy policy carefully.

After you successfully subscribe to the traffic package, we will monitor the information such as your usage, remaining amount and package validity to facilitate your review of package use and traffic management.


2.3 To Receive Your feedback

You may submit your suggestions or comments through this Service for any problem of your use of the Service, when we will collect your user ID, mobile phone model, application version number and detailed description or pictures. The above information will help us locate the problems of your use. We will not be able to help you solve the difficulties if you refuse to provide the above information. In order to get in touch with you and provide you with solutions, we will collect your mobile phone number or email address. The provision of such information is optional. When you upload pictures, we will access your camera rights, file and media rights. You will not be able to use the image upload function if you refuse to provide the authorization. However, it will not affect your normal use of other service functions. You may close your authorization at any time via Settings - Application Management - Rights Management - GENIEX.


2.4 To Provide You with Notifications Services

We may also send you service notifications, events, prizes and other messages based on your device identifier, operating system version, user nickname of current device, network information and information about your use of the app. To unsubscribe from notifications, events, prizes, etc., you can withdraw your consent via Settings > Notification Centre > Notification Management, permission management may vary for different versions.


2.5 To provide you with in station transportation marketing activities

When you use GENIEX products and services, we may collect your user ID, mobile phone model and application version number, and show you the promotion contents related to GENIEX operation activities. We will strictly protect your privacy in this process. We may create profiles by analyzing the above information and creating user groups (to save your personal information in one or more fields). Targeted advertisements will only pushed to you to the extent required by applicable laws and with your consent.


2.6 To improve our products or services

We may also collect other information about you that we reasonably need to improve our products or services, including IMEI number, Android ID, your page browsing, click, purchase and package consumption records. This kind of information will help us analyze our service function use statistics, generate group user portraits, and help us optimize service functions and page design, thus we can provide you with better service.


3. Other situations in which your information may be collected

Where permitted by law, we may obtain your personal information from other individuals, business entities, public channels or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.

We may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection and we will obtain your consent.

In order to better improve our product layout and provide you with great services, we may conduct research, statistical analysis and prediction on the collected information in an anonymized manner (including machine learning or model algorithm training by using anonymous data). We will take technical measures and other necessary measures to process such data, so that the data cannot be re-identified to specific individuals, nor can it be recovered. In accordance with the applicable laws and regulations, such processed data can be used without separately notifying you or obtaining your consent.


II. How We Store and Protect Your Personal Information

1. How we store your personal information

The personal information collected with your consent will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. To the extent not prohibited by local laws and regulations, we may also store the collected personal information in countries or regions outside the country where the business is located.

Currently, GENIEX may store your personal information in: Nigeria.

In particular:

The personal information collected and generated during our operations in Nigeria will be stored on servers located in Nigeria.

According to business conditions, we may use servers in other regions or countries in the future, and we will update this Policy at that time.

Whether we store personal information in the country where the business is located, or in other countries or regions to the extent that doing so does not violate laws and regulations, we will retain it in accordance with the relevant laws and regulations on data storage. At the same time, we will consider the characteristics, scope and purpose of personal information processing, the risks that may be encountered in the processing, and the serious consequences caused by the damage, etc., and implement the necessary security measures. For example, we will use encryption and de-identification methods to store the personal information collected. We will also keep the information for the shortest storage period specified by law. For those not specified by law, we will retain the information according to the shortest storage period required for business. For data that exceeds the storage period, or data that you request us to delete, we will delete said data accordingly or take other appropriate measures without violating the relevant laws and regulations.


2. How we protect your personal information

We will take other necessary measures to protect the security of your personal information and prevent data from being misused, unauthorized access, and unauthorized modification, disclosure or destruction, etc.

We implement security safeguards designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical, and physical safeguards to protect your personal information by taking the types of the personal information, the processing, and the threats posed themselves into account. We are constantly working to improve on these safeguards to keep your personal data secure.

Nevertheless, we need to remind you that no matter how perfect the measures are, there is no absolute guarantee of avoiding the occurrence of data storage security incidents. If a data breach event occurs, we will report it to the corresponding regulatory authorities as required by the relevant laws and regulations, and provide the type of personal data involved in the breach, the number of data subjects, the possible consequences of the breach, and the remedial measures we intend to take according to the requirements of the regulatory authorities. We will take the best possible measures to remedy or mitigate the damage and consequences of data breach. When permitted or required by laws and regulations, we will inform you of the possible consequences or significant damage to you in a timely manner, so that you can take appropriate measures promptly to protect your rights as much as possible.

There is no absolutely safe website, Internet transmission, computer system and wireless connections. In addition to the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when you access third-party websites, links, products or services from our services, for the security of any data collected by those websites, links, products or services, please read through the terms and conditions of those third-parties carefully. We do not take any legal responsibility for data security issues caused by such third parties. If you find that certain contents, advertisements or features in our websites, products or services may be provided by a third party and may possibly endanger your privacy and security, please contact us promptly, as we will handle it with priority in accordance with laws and regulations.


III. How We Share, Transfer and Disclose Your Personal Information and Data

When sharing, transferring, and disclosing your personal information, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your personal information externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your personal information in the following situations:

1. How we share your personal information

We do not sell any personal information to third parties. In order to provide you with timely services, your personal information may be shared with GENIEX affiliated companies. We will only share your information within GENIEX affiliated companies for legitimate and explicit purposes, and only share the information necessary to provide the services, and are bound by the purposes stated in this Privacy Policy. If a purpose concerned is not included in this Policy, we will state it in the corresponding privacy policy or notice of the specific product or service.

We may share the necessary personal information with authorized third-party partners (including technical service providers, data storage service providers, after-sales service providers, marketing promotion service providers, third-party SDK service providers, etc.) for the performance of certain features or to provide you with better service and a better user experience. For example, in order to enable you to share information to third party platforms, use location service and other kinds of services and features, we may embed third party SDK or other similar applications of authorized partners in this Application. We uphold the principles of minimization, necessity, and legality to carry out such sharing. Before sharing information, we will sign strict confidentiality agreements with authorized partners and require them to take relevant confidentiality and security measures to process personal information in accordance with this Policy and applicable laws in your jurisdiction. In addition, we will also require them to provide data security capabilities and information security qualifications (e.g., grade protection assessment, information security management system). When we embed the third party SDK or other similar applications of authorized partners in this Application, we will notify you promptly and request the SDK service provider that obtains the information to protect your data security.

In order to provide evaluation, analysis or other business services, we may also share your non-personal information with third parties. For example, we may use aggregated data to help partners (e.g., advertising service providers) understand the effectiveness, feedback and usage trends of their services.

In the event of a merger, acquisition or bankruptcy liquidation, asset transfer and other related transaction, if a personal information transfer is involved, we will require the new entity or organization holding your personal information to continue to be bound by this Policy through an agreement or other appropriate measures, and we will require such subject to take confidentiality and security measures of a degree no less than the requirements of this Policy to process personal information.


2. How we transfer your personal information

GENIEX will not transfer your information to any other parties, except in the following circumstances:

(1) Obtain your explicit consent.

(2) If GENIEX is involved in a merger, acquisition or sale of all or part of its assets, which may affect your personal information, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your rights of your personal information, and any choices you may have about your personal information.

(3) In the case that has been explained in this privacy policy or notified you by other means.


3. How we disclose your personal information

According to the legal requirements, legal procedures, litigation and/or requests from government departments and authorities, GENIEX may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.

Additionally, we may share your personal information with:

(1) Our attorneys, lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.

(2) Investors and other relevant third parties, if actual or potential sales or other company transactions occur and are related to entities within our group.

(3) Other third parties, for example, the disclosure of specific information with your authorization.


IV. How Your Personal Information is Transferred Across Borders

For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may transfer your personal information to the resources or servers stipulated in section III of this Policy for storage or processing, we may also transfer your personal information to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions. The privacy protection laws of these countries or regions may be different, and the jurisdiction in which these global resources or servers are located may or may not protect personal information to the same standards as in your jurisdiction. However, we will still strive to comply with our Privacy Policy to protect your personal information, and we will follow the legal requirements of the country or region where the personal information is located to carry out the corresponding cross-border transfer and other processing of personal information.

In the circumstance that we transfer personal information outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.


V. Your Rights to Your Personal Information

As a data subject, you have a series of rights to your personal information, including the right to confirm, access, correct, delete, withdraw consent, and lodge complaints (hereinafter referred to as “request”). We fully understand and respect your rights, and such rights will be subject to specific exclusions and exceptions under applicable laws. We will also take active steps to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others or are extremely impractical, or violate the mandatory provisions by law.


1 Right to confirm and access

We inform you how we collect and process personal information through this Policy or in the form of a privacy policy or notice of the specific product or service. You have the right to confirm or reject such collection and processing via a check box or other methods. However, after you reject, some features that require your explicit authorization and consent to use may no longer be available. You can directly access the personal information you have provided to us in the interface of our products or services. For those that you are unable to access, you can send an email to [user-services@geniex.com]. We will handle it promptly after receiving your email.


2 Right to correct and delete

When your personal information is changed, or when you find that your personal information collected and processed by us is inaccurate or incomplete, you have the right to ask us to make corrections or additions. You can directly correct or modify some of your personal information on the relevant product/service function pages. When your personal information collected by us has fulfilled the purpose of collection or is no longer required, or when you find that our collection and processing of your personal information violates the provisions of laws and regulations or this Privacy Policy, you have the right to ask us to delete the relevant personal information. For personal information that we have not provided you with a channel for correction or deletion, you can request that it be corrected or deleted by contacting [user-services@geniex.com].

However, we may not grant your deleting request in some situations, for example, if you ask us to delete your transaction data when GENIEX is legally obligated to keep a record of that transaction to comply with the applicable local law. Please also kindly note that if you request to delete your information from our products and services, we may not remove the corresponding information from the backup system immediately due to some applicable local laws and technological limitations, however, we will securely store your personal information and isolate it from any further processing until the backup is updating or can be deleted or be made anonymous.


3 Right to withdraw consent

To achieve the respective features of our various products or services, we will require necessary personal information in accordance with the applicable local laws. This is described in the "How We Collect and Use Your Personal Information" part of this Policy. You can withdraw your consent previously granted to us for a specific purpose by deleting information, turning off device features, and requesting to withdraw consent, including the collection, use and/or disclosure of your personal information that we manage or control. You can email us at [user-services@geniex.com] for above operations. We will process your request within a reasonable time after you send the request, and thereafter will not collect, use and/or disclose your personal information in accordance with your request.

If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of GENIEX and its Service. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.


4 Right to complain

You have the right to lodge a complaint by sending us an email at [user-services@geniex.com]. We will respond promptly after receiving your complaint. If you are unsatisfied with our response, especially if our processing of personal information violates your legitimate rights and interests, you may refer your complaint or report to your local statutory personal data protection department, or file a lawsuit with a competent court.


5 Right to control your privacy settings

You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your personal information via such privacy settings. For example, you can prefer turn on or turn off the permissions of “Location Access”, “Camera”, “Text Message”; you can also obtain detailed information regarding the device security status in “Settings”. If you have agreed to such permission or have agreed to our use of your information previously for the above-mentioned scenarios. You can turn it off via “Permission Management” > “App Permissions” or contact us via [user-services@geniex.com] to change your decision.


6 Right to cancel a service or account

You can request to cancel through the “Logout” settings provided in the service or by contacting us via [user-services@geniex.com]. Please take full consideration before canceling your account. You acknowledge and understand that after you cancel your account, we will stop the products and services provided based on the account. Unless otherwise required by the applicable laws of the region you reside in, we will delete your personal data under your account. If you are authorized to log in to this Service through a third-party account, please apply to the third party for account cancellation.


7 Rights in some jurisdictions

Particularly, according to the applicable laws of some jurisdictions, you may have the following data subjects rights:

(1) Right to restriction processing. You have the right to request our restriction on the processing of your personal information. We shall consider the grounds regarding your restriction request. If the grounds are in the compliance with applicable data protection laws, we will process your personal information under applicable circumstances in such laws and notify you before the restriction of processing is lifted.

(2) Right to automated decision-making. You have the right to refuse the processing based on automated decision-making, including profiling and other automated processing which may have legal or similar effects on you.

(3) Right to data portability. You have the right to apply for your personal information to be transmitted to another data controller in a structured and commonly used format.

We have the right to refuse to process your requests or only respond to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are manifestly unfounded or obviously excessive or it requires the disclosure of information of third parties.


VI. How We Handle the Personal Information of Children

GENIEX does not provide our products or services to children under the age of 14 or the equivalent age as specified by law in your jurisdiction (we will define children mainly based on the laws and regulations of the country or region where our business is located because laws of different countries may differ when defining the age of children). We do not knowingly collect children’s personal data or use children’s personal information for the purposes of marketing. If you find that a child’s information has been collected to us, please send an email to [user-services@geniex.com] to contact us. We will remove the relevant information as soon as possible. If we become aware that a child has provided us with personal information, we will take steps to delete their personal information from GENIEX as soon as possible.


VII. Third-Party Service Providers and Services

With the upgrades of this Application, you may receive links to third-party websites or content and services provided by third parties other than us during your use of GENIEX and its Service, and some third parties’ products or services can be accessed in the form of SDKs and others. You can choose whether to visit or accept the third-party websites, products, and services at your sole discretion. Our Privacy Policy does not apply to products and services provided by any third party. Since we are not able to substantially control a third party, we are not responsible for the third party’s collection and processing of your personal information. Therefore, when you submit any information to a third party, please carefully review the third party’s privacy policy and take care of your personal information.

The content of [GENIEX] and its services described herein may vary according to the type of product you use, your system version, or requirements of local laws and regulations.


VIII. Supplement and Update of the Policy

We reserve the right to update or modify this Policy from time to time in order to reflect the changes in our business, technology and applicable law and practice. In case of any modification of this Policy, we will notify you of the latest Policy by posting it on [My - About Us - Private Document], or sending you separate notifications. Please follow this web page and the notifications we send to you for the latest updates of this Privacy Policy. Although this Privacy Policy may be modified, your rights under this Policy will not be diminished without your explicit consent.

We will ask for your explicit consent again in accordance with applicable laws before we collect additional personal information from you or when we use or disclose your personal information for new purposes. Your continued use of the products and services on the website, mobile and/or any other device constitutes your agreement to the updated Privacy Policy.

The content of GENIEX and its services described herein may vary according to the type of product you use, your system version, or requirements of local laws and regulations.


IX. Joint Controller

[TRANSTECH(SHENZHEN) LIMITED] is a joint controller with us and we are jointly responsible for processing your personal information. [GENIEX-TECH NIGERIA LIMITED] and [TRANSTECH(SHENZHEN) LIMITED] have allocated respective responsibilities according to applicable laws. You can contact us for more details regarding the joint controllership by the contact information in section x. "How to Contact Us".


X. How to Contact Us

If you have any comments, questions or concerns with respect to our Privacy Policy or practices of personal information protection, please contact us via:

Email: [user-services@geniex.com] (Note: This mailbox is used for receiving messages related to our Privacy Policy or our protection of personal information only)

We will review your privacy or personal information requests as soon as possible and respond to you in 15-30 days after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.

If you are not satisfied with our response, especially when you believe that your legitimate rights and interests have been violated by us, you can seek remedy from relevant data protection regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your circumstance.

Thank you for your time to read our Privacy Policy!